On December 30, 2015, the Department of Defense ("DOD") revised the Defense Federal Acquisition Regulations Supplement ("DFARS") interim rule on required cybersecurity measures for defense contractors. As published in August 2015, the revised DFARS clause 252.204-7012 required contractors to provide "Adequate Security" for Covered Defense Information by implementing the security requirements of the NIST Special Publication 800-171, "Protecting Controlled Unclassified Information in Nonfederal Information Systems and Organizations." After publishing that rule, the DOD issued a class deviation allowing contractors up to nine months for implementation of security requirements. The December 30, 2015, Interim Rule gives contractors additional time to implement the requirements of NIST SP 800-171 and incorporates a number of changes that will affect contractors' cybersecurity compliance policies. For further discussion on the revised DFARS interim rule, see the Jones Day Alert.

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